Continuing our series on navigating ink-related food safety standards
In two previous blogs we have explored hazard analysis and risk management, and record keeping. In this blog we will focus on the third standard, traceability.
If you produce labels and packaging for the food market, you must have a system for tracing ink batches to each job. Traceability is essential for quickly identifying the root cause of problems and recalling affected products. Therefore, suppliers must demonstrate the ability to trace raw materials to specific jobs to meet industry safety standards. And in fast-flowing food and pharmaceutical value chains that are constantly on-the-move, suppliers must be able pinpoint any problematic batch or order – at very short notice.
In this blog, you will discover the standards that matter, the challenges of traceability when using leftover inks in new jobs, and the software tools that can help you comply. Given the impact on brand reputations, compliance is non-negotiable.
We will include relevant hyperlinks to web pages and recommend additional reading on our InkConnection blog site, where applicable.
Requirements concerning traceability in the three food safety management schemes
The criteria regarding traceability can be found in:
- Section 3.11 of the BRC Global Standard (BRCGS) for Packaging Materials
- Sections 1.9 and 2.12 of FSSC 22000 (Food Safety System Certification)
- Section 2.6 of Safe Quality Food (SQF).
Below we summarize the requirements of these three schemes.
Traceability system
The production site must have a documented traceability system in place for every product that meets regulatory and customer requirements. This fully operational system must include work-in-progress, post-treatment and rework. All purchases of ingredients and raw materials needed to fulfil the customer order and make the end-product must be recorded, maintained, well-organized, securely stored and readily available.
Product identification: one step back and one step forward
The site must be able to identify the immediate supplier of purchased products (one step back) required by laws, regulations, or specific industry needs.
One Step Backward (Supplier Traceability):
This refers to the ability to trace the origin of the materials or components used in a product, including the date of receipt. For example, if you have a finished food package, you should be able to trace back to the suppliers of the ink ingredients used to print that product.
The complicating factor however with ink traceability is that spot colours are blended from a formula of base components.
A good traceability system ensures that if there’s a safety concern or a quality issue, you can quickly identify which suppliers provided the ingredients or materials that went onto the package.
One Step Forward (Customer Traceability):
This refers to the ability to trace where your products have been distributed or sold to. Essentially, it means you should be able to identify which customers received the packages that were produced using specific ingredients or materials.
The site must clearly identify all raw materials, recycled materials, and products at every stage (receipt, production, storage, dispatch). Clear labeling procedures must ensure continuous product identification throughout these stages. For continuous processes or bulk silo storage, traceability should be maintained to the highest practical level of accuracy.
Reworking inks
Traceability must be also maintained for reworked products. With spot colours, any ink remaining in the press after a job is returned for reuse, either for the same colour or as an ingredient for a new one. Consequently, traces of a batch can go through multiple dispense-production-return cycles and various jobs over time. Therefore, when using return inks in new jobs, the base components and their batch codes of reworked press-return inks must also be identified.
Traceability system tests
The traceability system must be tested and documented at least annually as part of the product recall and withdrawal review. This includes testing both incoming materials (one step back) and finished products (one step forward) from different shifts and across various products and customers. The system must be verified as effective and updated as necessary.
You will be expected to perform a traceability exercise, within a designated time limit (BRCGS stipulates a 4-hour limit). To pass, you must recover a minimum 98% of all selected materials. Failure can constitute a major violation and, in some cases, automatic failure.
Maintaining records
The traceability system must maintain the following records:
- Purchased products and their immediate suppliers, including raw materials with batch codes and delivery dates.
- Customers and end-product deliveries.
- Batches of in-process or final products and packaging throughout production.
- Post-processing and rework activities.
- Annual testing of the traceability system.
- Updates to the system as necessary.
GSE Traceability software for complying with traceability requirements
Database systems capable of storing and retrieving detailed supplier and customer information are essential for complying with GFSI requirements and performing traceability exercises within 4 hours. Although ERP systems often include traceability modules for tracking suppliers and customers, they cannot trace batch codes when spot colors are blended from base colors or when press return inks are recycled.
To address this, GSE has developed a software suite for traceability compliance. When GSE Traceability software is activated, users must input a batch code every time a barrel is exchanged at the dispensing system. Each dispense job in the job list generates a unique container ID. Batch codes for each component are stored with the job / container details in the database. An optional label printer and barcode reader can label containers with the ID and ingredient details, aiding traceability.
The software enables instant creation of traceability reports, which can detail either batch-to-job (customer traceability) or job-to-batch (supplier traceability) sequences. These reports include container IDs, formulas, production dates, and expiry dates of freshly dispensed inks. Batch codes of previous and subsequent barrels are also reported to maintain traceability accuracy when barrels are partially filled with leftover ink from previous batches. This helps identify ink batches when there are safety or quality concerns with a known timeframe but unknown batch codes.
GSE Traceability software solves the problem of tracking ink batches through their complex journeys in the printing house.
Advanced logistics to eliminate administrative errors
Integrating GSE Traceability with the optional GSE Advanced logistics software streamlines planning, ordering, and booking base components delivered by your ink supplier. This integration enables tracing ink batches through the value chain and eliminates administrative errors. After raising a purchase order in the software, ink barrels can be booked in upon delivery. A unique barrel ID is generated, and the warehouse manager inputs relevant data such as batch code, expiry date, and delivered weight. When an ink barrel that is connected to the dispensing system runs empty, the operator selects a new barrel from the inventory, and the delivery data is incorporated into all logistic events and reports.
Integrating with your ERP system to enhance traceability reports
Using GSE Traceability with the GSE Order management software module enhances traceability reports with sales order information. Integrating GSE Order management and GSE Traceability with management information systems (MIS) and ERP software, like the standard integration with CERM, makes traceability an automatic affair, with minimal human input. It allows data from scanned container IDs of spot colors prepared for a printing job to be automatically stored with the customer order in CERM, for easy retrieval during a traceability exercise.
Hassle-free identification and traceability of return inks
GSE Traceability also solves the problem of tracing return inks. When used with the GSE Return ink management module, it can track a returned spot color ink through up to 99 dispensing cycles. Traceability reports include container IDs, formulas, order numbers, storage locations, and expiry dates of the return inks used in new dispense jobs. Each return container can also be labeled with its unique container ID for easy identification.
Further reading on the InkConnection blogsite
- Ink traceability: the key to safety and compliance in food and pharmaceutical value chains
- Meeting quality standards for packaging inks with GSE Traceability
- Good order management for spot colours
- Integrating ink management software with MIS for optimum performance!
- How to keep ink inventories for spot colours at optimum levels
- Logging ink consumption and exchanging barrels at the dispenser
- Effortlessly reusing press return inks for spot colour printing: a best-practice guide
By implementing a robust traceability system, you not only ensure compliance with regulations but also enhance your ability to manage quality control, respond to incidents promptly, and build trust with consumers and regulatory bodies alike.